Hazardous Waste Storage Procedures
Two types of hazardous waste accumulation points are present at Clemson University’s main campus:
- Accumulation Points
- Satellite Accumulation Points
A hazardous waste accumulation point is a location on-site at which hazardous waste can be accumulated for up to 90 days without a permit. At an accumulation point, any amount of hazardous waste can be collected and stored providing no container remains in the accumulation point storage for over 90 days. If hazardous waste is added to a container at the accumulation point, the 90-day limit for that container begins as soon as the first waste is added to the container. For this reason, container size selection is very important in minimizing costs when accumulating in these areas. Estimate your waste volume carefully while allowing for extra time to arrange shipping. It is recommended that you chose a container size that you can fill within a 30 or 60-day period in this situation.
A satellite accumulation point is a location at or near the point of generation that is under the control of the operator of the process generating the waste. No more than 55 gallons of hazardous waste or one quart of acute hazardous waste can be accumulated at a satellite accumulation point.
The difference between a satellite accumulation point and an accumulation point are the volume and the length of time wastes may be accumulated. At a satellite accumulation point, up to 55 gallons of hazardous waste or up to one quart of acute hazardous waste may be accumulated for a reasonable amount of time. At an accumulation point, an unlimited volume of waste may be accumulated in containers for up to 90 days. If a facility has not been approved by the Hazardous Waste Officer to maintain a hazardous waste accumulation point, then they are, by default, satellite accumulation points and must stay in status with the volumes stated above.
The Office of Research Safety operates the Central Hazardous Waste Accumulation Building on main campus. No hazardous waste shall be stored at an Accumulation Point at Clemson University’s main campus for greater than 90 days from the accumulation date on the container.
Maps of the Central Hazardous Waste Accumulation Building site and any other Accumulation Areas/Sites approved by the Hazardous Waste Officer will be maintained in the Hazardous Waste Incident Contingency Plan and/or at the Hazardous Waste Management Facility.
Hazardous waste must be kept in designated areas at all times. Wastes that are accumulated in these areas must be managed in accordance with the procedures specified below. The generator is responsible for ensuring compliance with these procedures for his/her hazardous waste satellite accumulation point(s). The Hazardous Waste Officer is responsible for managing the Central Hazardous Waste Accumulation Building(s) in compliance with these procedures.
All hazardous waste Accumulation Points must meet the following requirements:
- A Hazardous Waste sign must be posted at each area.
- The name and phone number of the accumulation point supervisor and an alternate contact must be posted at each area.
- The area should be used for hazardous waste accumulation only. No raw materials or chemical stock should be stored in the same area with hazardous waste.
- Flammable materials cabinet shall be used when possible for storage of ignitable hazardous wastes.
- The area must be located at or near the point of waste generation and must be under the control of the person responsible for the waste-generating process.
- All containers will be appropriately labeled and segregated for compatibility.
Access to the hazardous waste accumulation points and building must never be blocked. The area shall be quickly and easily accessible by emergency response personnel in the event of a spill, leak or fire. Appropriate emergency response equipment shall be maintained for each hazardous waste accumulation and satellite area. The accumulation point supervisor is responsible for ensuring the equipment is in good condition at each of his/her accumulation points. The Hazardous Waste Officer is responsible for the Central Hazardous Waste Accumulation Building(s). Emergency equipment shall include the following:
- Fire extinguisher, 20lb ABC type.
- Absorbent of the proper type and of sufficient amount to absorb the volume present.
- Broom, bucket and mop.
- Telephone or other communication device.
- First aid kit.
- Safety shower and eye wash station as applicable.
- Coveralls, eye protection and gloves compatible with wastes.
- Empty containers and bags compatible with cleanup characteristics.
The accumulation point shall be managed as follows:
- The person responsible for the area must meet the Occupational Safety and Health Administration (OSHA) requirements for hazardous waste training contained in 29 CFR 1910.120 and Department of Transportation (DOT) HM-181/ HM-126F.
- Waste shall be stored in approved containers.
- Containers shall be kept closed except during waste transfers.
- Inspections shall be conducted weekly (see Section III.E).
- Incompatible materials shall not be combined into one container. Containers of incompatible materials shall be separated to protect against mixture in the event of a spill, leak or release (see EPA compatibility table - Table III-1).
- Containers shall be labeled with an approved hazardous waste label before any waste is received (see Section III.B).
Satellite accumulation points are subject to the following requirements defined below:
- No more than 55 gallons total of hazardous waste or one quart total of acute hazardous waste may be accumulated. See Appendix A for a list of acute hazardous wastes.
- Containers with the excess must be dated as soon as 55 gallons of hazardous waste or one-quart total of acute hazardous waste or more are accumulated. All subsequent containers will be dated upon initiation of the first addition of waste until the site’s status is returned to a Satellite Accumulation point by the reduction of wastes at the site to meet the less than 55 gallons of hazardous or less than one quart of acutely toxic waste limit. This should be accomplished within 3 days. In order to minimize the establishment of new Accumulation Points, containers must be moved to an established or central accumulation point within three days of the date the storage volume limits are exceeded, unless permission to establish a new Accumulation Point is obtained from the Hazardous Waste Officer.
In order to minimize the risk of hazardous waste incidents and in order to comply with published regulations, each site of hazardous waste generation will be considered a satellite accumulation point unless designated otherwise by the Hazardous Waste Officer. This will be particularly useful considering the large number of laboratories generating hazardous waste on campus.
In spite of the flexibility allowed in the regulations concerning volume limits at satellite accumulation points, it will be Clemson University’s procedure to pick up hazardous waste on demand. This will also minimize the risk of potential hazardous waste incidents by not allowing undue accumulation of waste.
Waste Storage Containers
Hazardous waste shall be placed only in approved hazardous waste containers. An approved hazardous waste container is made of or lined with a material compatible with the waste. Empty containers, which originally held the primary waste constituent or similar material, are acceptable hazardous waste containers. The original container label must be removed or defaced. An approved hazardous waste label with the appropriate information shall be affixed to the container before any hazardous waste is received. (Container labeling requirements are summarized in Section III.C)
The container must be in good condition without holes, rust or dents. The container shall always be closed during storage, except when waste is being added or removed. A hazardous waste container shall not be opened, handled or stored in a manner that may rupture the container or cause it to leak. Consideration should be given to doubly contain certain particularly dangerous chemicals if storage conditions and limitations are not ideal.
If drums are stacked in the Hazardous Waste Accumulation Building, pallets shall be used to separate the containers, and stacking and spacing shall meet applicable fire protection requirements. Aisle spacing for container storage in the Hazardous Waste Accumulation Building shall be such that each row of containers can be easily inspected for leakage or damage.
Labeling and Marking
An approved hazardous waste label (Figure III-1) shall be affixed to each hazardous waste container prior to receiving any waste material. The Hazardous Waste Officer is responsible for ensuring each container is properly labeled before being picked up from a Satellite Accumulation Point or an Accumulation Point and moved to the Central Accumulation Point. However, the Generator or Accumulation Point Supervisor responsible for the waste is responsible for ensuring each container in his/her area is properly labeled before placing waste into the container or receiving any waste into an Accumulation Point.
The following information shall be provided on each hazardous waste label:
- HAZARDOUS WASTE - Federal law prohibit improper disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
- The specific chemical name of the hazardous waste in the container shall be identified (e.g., waste acetone), including percentages of constituents if more than one.
- Each container shall be appropriately labeled with the EPA Hazardous Waste Number(s) at the Accumulation Point or the hazard(s) exhibited by the waste while in the Satellite Accumulation Point.
WASTE CONTAINERS ARE REQUIRED TO BE LABELED, BY THE GENERATOR, AS SOON AS THE FIRST DROP OF WASTE IS PLACED INTO THE CONTAINER!
The labels shall be placed on the side of each container in such a manner that they are clearly visible for inspection.
Up to 55 gallons total of hazardous waste or one quart total of acutely hazardous waste may be collected in each satellite area. The accumulation point supervisor is responsible for notifying the Hazardous Waste Officer as soon as 55 gallons of hazardous waste or one quart of acutely hazardous waste have been collected (see Section IV). Each container that is stored in the Central Hazardous Waste Accumulation Building or at any other Accumulation Points shall have the accumulation start date on the label.
Accumulation Time Limits
Up to 55 gallons total of hazardous waste or one quart total of acutely hazardous waste may be collected in each Satellite Accumulation area. Once 55 gallons of hazardous waste or one quart of acutely hazardous waste has accumulated, the Generator shall date the container(s) containing the excess waste. The container(s) must be moved to a designated university Accumulation Point or picked up for off-site disposal within three (3) days of declaration to the Hazardous Waste Officer. Within 90 days of the accumulation start date, the container must be shipped off-site for disposal at an approved RCRA disposal facility. Hazardous waste may not be stored on-site at a designated Accumulation Point for greater than 90 days from the date it is first accumulated.
The applicable accumulation point supervisor shall conduct weekly inspections of the hazardous waste accumulation points and a copy kept on file at the site. The Hazardous Waste Officer or his/her qualified designee shall inspect the Central Hazardous Waste Accumulation Building(s). During the inspection, the inspector shall check each item listed on Figure III-4. The results of the inspection shall be documented on this form. A copy of the form shall be sent to the Director of Research Safety and one copy retained on site for inspection.
If any corrective action is required, the Accumulation Point Supervisor must comply immediately. Once the problem has been corrected, the Accumulation Point Supervisor is to date and initial a copy of the form and mail it to the Hazardous Waste Officer. The Hazardous Waste Officer shall maintain these records for three years.
Satellite Accumulations Points will be audited for regulatory compliance at each requested waste pick up. A written notification of any compliance deficiencies will be sent to the Faculty Member and/or the PI responsible for the area. A copy of the written notification may be sent to the appropriate Dean, Department Head or Director as well as the Director of Research Safety. A copy will also be kept on file at the Hazardous Waste Central Accumulation Point maintained by the Office of Research Safety. It will be the sole responsibility of the Department or Division to correct deficiencies.
Record keeping and reporting
During the weekly inspections of the departmental accumulation points and the Central Hazardous Waste Accumulation Building(s), the current inventory of waste shall be recorded (see Section IV). The Hazardous Waste Officer, for the purpose of coordinating shipments of hazardous waste, shall use this inventory.
Within 30 days after the end of each calendar quarter, a written report must be submitted by the Hazardous Waste Officer to SCDHEC summarizing the hazardous waste activities for that quarter. In addition to general facility information, the report must include the following information:
- Hazardous waste transporters used during the quarter to transport the waste to a treatment or disposal facility.
- The types and quantities of hazardous wastes generated, including the EPA waste number and the DOT hazard class.
- The types and quantities of wastes shipped off site during the quarter.
- The types and quantities of waste remaining in storage at the end of the quarter.
- A description of waste minimization and toxicity reduction efforts for the year (to be included with the fourth quarter report). And
- A description of the effectiveness of the waste minimization and toxicity reduction efforts using comparisons to previous years (to be included with the fourth quarter report).
- All quarterly reports must be maintained at the facility for at least three years from the date the report was filed.
Personnel who handle or are occupationally exposed to hazardous waste are required to be trained initially in the proper methods for the management of hazardous waste and the implementation of the facility’s contingency plan. The training program must be directed by a person trained in hazardous waste management. Personnel who are assigned to a position related to hazardous waste management must complete training within 90 days of their assignment. These personnel must not work in unsupervised positions until they have successfully completed training. Refer to Section VII for details regarding who must be trained and the scope of the required training.